§TONJE OAK~ LJUC 

March 23,2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Madam, Sir, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act"), 

P.L. 112-95, 'Special Rules for Certain Unmanned Aircraft Systems" and 14 C.F.R. Part 11, 

Stone Oak LLC. ("Stone Oak"), seeks an exemption from the Federal Aviation Regulations 

("F ARs") as listed below: 

• 14 C.F.R. 21 

• 14 C.F.R. 45.23 

• 14 C.F.R. 45.29 

• 14 C.F.R. 61.23 

• 14 C.F.R. 61.3 

• 14 C.F.R. 61.113(a) (b) 

• 14 C.F.R. 61.133(a) (b) 

• 14 C.F.R. 91.7(a) (b) 

• 14 C.F.R.91.9 

• 14 C.F.R. 91.109 

• 14C.F.R.91.119 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.203 

• 14CFRSubpartE(91.401-91.417) 

The name and contact information for this application is: 

Richard A. Korgan 

Stone Oak LLC 

19400 Redbud Drive 

Catoosa, Oklahoma 74015 

Tel: 918-691-8448 

e-mail: rkorgan@gmail.com 
The requested exemption would authorize Stone Oak to perform commercial operations that 

would enhance their existing services to perform mapping services, including but not limited to 

imaging for Precision Agricultural applications, Digital Terrain Modeling, Accident 

Reconstruction, Infrastructure reconnaissance and inventory with GIS applications for Private, 

Local, State and Federal entities, land surveys that would include Riparian Boundaries of State 

and Federal owned lands associated with navigable rivers. 

These services will be augmented by use of either or both of the following: 

• The eBee, a fixed wing Unmanned Aircraft System (UAS) manufactured by SenseFly, A 

Parrot Company ("SenseFly"). 

• The UXS and UXS HP ("UXSIHP"), fixed wing UAS's manufactured by Trimble 

Navigation Limited ("Trimble"). 

These operations will be subject to strict operating requirements and conditions defmed in the 

eBee and UXSIHP user manuals (while the documents are included with this request, Stone Oak 

hereby requests that the FAA treat the eBee and UXS/HP user manuals as proprietary under 14 

C.P.R. 11.35(b) and does not include their documents in the public docket). 

With Regard to the SenseFly eBee UAS: 

1. CHARACTERISTICS OF THE AIRCRAFT 

The eBee is a small fixed wing (37.8 inch wingspan) and ultra-light (maximum take-off weight of 

1. 7 pounds) platform made of flexible foam that performs pre-programmed precision aerial 

mapping missions using the on-board GPS and the related flight management software (eMotion) 

that allows the operator to plan safely and efficiently a mission in 3D, and then monitor it in realtime. Using an embedded camera, protected by the airframe foam envelope, the eBee takes a 

collection of high-definition still images that are used later to generate maps and contour lines of 

the surveyed area. 

The four main characteristics of the eBee are: 

a. Very light weight 

The eBee is so light that the operator can launch it by hand and let it land on almost any surface 

without requiring a parachute or landing net (belly land). Its low impact energy (38 J in case of a 

controlled emergency landing) also significantly reduces the risk of hazardous situations. Finally, 

the wings of the eBee are detachable and made of flexible foam with no sharp or hard edges and 

almost no internal strengthening structure. 

b. Electric-powered 

The eBee is electric powered. A brushless engine technology makes it silent and reliable. The 

propeller is attached with a rubber band to the body of the plane so that it can easily flex away in 

case of contact with any object. 

c. Semi-automatic flight 

The artificial intelligence incorporated within the eBee autopilot system continuously analyzes 

data :from the Inertial Measurement Unit and :from the onboard GPS and takes care of all the 
Stoillle Oak 13 

aspects of the flight under the supervision of the operator. 

d. Option for Manual control 

Additionally, the eBee provides an override capability that allows the operator to take manual 

actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend 

automated operations and take manual control of the aircraft should it become necessary to 

respond to emergent circumstances, thanks to the remote controller provided with the system. 

2. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Airworthiness assessment of the eBee 

Stone Oak notes that the airworthiness of the eBee has already been demonstrated for different 

projects in the United States, involving state/federal agencies or universities (among others the 

New Mexico State University: https ://newscenter .nmsu.edu/ Articles/view II 0208/nmsu-uas-flighttest-center-conducts-ebee-airworthiness-assessment, and the USACE New Orleans, who 

coordinated with the Department of Army and the FAA to obtain all authorizations required in 

order to operate the eBee UAS). Moreover the eBee has already received 15 Exemptions from the 

FAA. 

SenseFly also obtained flight approvals for the eBee (delivered by national civil aviation 

authorities) in many countries, among others: 

• Switzerland (flight approval for VLOS operations) 

• Canada (flight approval for VLOS operations) 

• Australia (flight approval for VLOS operations) 

• France (flight approval for Extended-VLOS operations) 

• Germany (flight approval for VLOS operations) 

• United Kingdom (flight approval for VLOS operations) 

• Norway (flight approval for VLOS operations) 

• Sweden (flight approval for VLOS operations) 

• Denmark (flight approval for VLOS operations) 

With Regard to the Trimble UX5/HP UAS: 

1. CHARACTERISTICS OF THE AIRCRAFT 

The UX5/HP is a small fixed wing (39.9 inch wingspan) and ultra-light (maximum take-off 

weight of 11 pounds) platform with a 5.1 pay load capacity. The aircraft is composed of a 

combination of carbon structure and EPP foam that will perform pre-programmed precision aerial 

mapping missions using the on-board GPS and the related flight management software that allows 

the operator to plan safely and efficiently a mission in 3D, while monitoring the mission in realtime. Using an embedded down-looking hi-resolution camera the UX5/HP takes a collection of 

high-definition still images that are used later to generate maps and contour lines of the surveyed 

area. 

The four main characteristics of the UX5/HP are: 

a. Very light weight 

The aircraft system includes a ground launching mechanism that enables the operator to launch 
the UX5/HP hands free. Its low impact energy also significantly reduces the risk of hazardous 

situations. Finally, the wings of the UX5/HP are detachable and made of flexible foam with no 

sharp or hard edges and almost no internal strengthening structure. 

b. Electric-powered 

The UX5/HP is electric powered. A brushless engine technology makes it silent and reliable. The 

propeller is attached to the electric motor in such a way that it can easily flex away in case of 

contact with any object. 

c. Semi-automatic flight 

The artificial intelligence incorporated within the UX5/HP autopilot system continuously analyzes 

data from the Inertial Measurement Unit and from the onboard GPS and takes care of all the 

aspects of the flight under the supervision of the operator. The UX5 HP in particular utilizes 

additional electronics to record its known position relative to another station with known 

coordinates. 

d. Option for Manual Control 

Automated operations can be suspended during the flight to take manual control of the aircraft 

should it become necessary to respond to emergent circumstances. The UX5/HP provides an 

override capability that allows the operator to take manual actions. 

2. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Airworthiness assessment of the UX5/HP 

On December 10, 2014 Exemption 11110 was issued to Trimble Navigation Limited, and later 

amended on May 7, 2015 with issuance of Exemption 1111 OA in FAA Docket 2014-0367. 

Exemption 11110 and 1111 OA allowed an Applicant to operate the UX5 and the UX5 HP 

aircraft manufactured by Trimble or other Trimble aircraft approved for commercial operations 

under Exemptions 11110 and 1111 OA, as they may be amended in the future. Applicant notes 

that, in Exemption 11257, the FAA also recently authorized use of the Trimble UX5 by a third 

party under conditions like those in Exemption 1111 OA. 1 Stone Oak hereby confirms that it will 

accept the conditions in Exemptions 11110A as well as those set forth in Exemption No. 1257, 

Regulatory Docket No. FAA-2014-0889 and will operate the aircraft in strict compliance with the 

conditions in existing exemptions previously granted by the FAA, or as they may be amended. 

With Regard to the SenseFly eBee UAS and the Trimble UX5/HP UAS: 

3. CONDITIONS AND LIMITATIONS 

Grant of the exemption to Stone Oak for the eBee and the UX5/HP will be subject to the 

following operating conditions: 

1. Operations authorized by this grant of exemption are limited to the aircraft weighing 

less than 55 pounds including payload. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this exemption. 

Exemption No. 11257 to Montana Land Surveys (see Docket No. FAA-2014-0889). 
Stone Oalk /5 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UAS may not be operated at a speed exceeding 87 knots (100 miles per hour). 

The exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UAS be operated at 

airspeeds greater than the maximum UAS operating airspeed recommended by the 

aircraft manufacturer. 

4. The UAS must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the Pilot-InCommand (PIC) at all times. This requires the PIC to be able to use human vision 

unaided by any device other than corrective lenses, as specified on the PIC's FAAissued airman medical certificate or U.S. driver's license. 

6. All operations must utilize a visual observer (VO). The UAS must be operated within 

the visual line of sight VLOS of the PIC and VO at all times. The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. 

The VO and PIC must be able to communicate verbally at all times; electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the duration 

of the flight. The PIC must ensure that the VO can perform the duties required of the 

vo. 

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator's responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an amendment to its grant of exemption. The FAA's UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 
S:toltlle Oak 16 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

U AS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

U AS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer's maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA 

airman medical certificate or a valid U.S. driver's license issued by a state, the District 

of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The 

PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an 

aircraft in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 14 

CFR § 61.51(b). Flights for the purposes of training the operator's PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC's ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UAS 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UAS may not operate within 5 nautical miles of an airport reference point (ARP) 

as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport's 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 

17. The UAS may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 
Stol!1le Oak 17 

18. If the UAS loses communications or loses its GPS signal, the UAS must return to a 

pre- determined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UAS to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request. 

24. The UAS must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a) Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UAS and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UAS, flight operations must cease immediately in a 

manner ensuring the safety of nonparticipating persons; and 

b) The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that 

it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 
28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defmed by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 

4. CONCLUSION 

Stone Oak hopes that this Petition for Exemption satisfies the criteria articulated in Section 333 of 

the Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and 

populated areas, operation within VLOS and national security. The proposed UAS operations 

will benefit the public as a whole by improving safety and reducing risk by alleviating human 

exposure to danger. In consideration ofthe foregoing, Stone Oak further hopes that since the UAS 

will be operated in strict compliance with the conditions in existing exemptions previously 

granted by the FAA, or as they may be amended, notice need not be provided in the Federal 

Register nor public comment solicited. 

Manager 

rgan~ 

Stone Oak, LLC